- The ISA digitalisation initiative aims to provide a “modern, digital service fit for the 21st century.” Discussions have been held with industry via a collaboration forum, with feedback used to shape the new requirements for reporting.
- HMRC are yet to publicly confirm what will be included in the amendments. However, some of the expected changes to ISA reporting are as follows:
- In addition to the existing annual reporting, HMRC are looking to introduce monthly ISA reporting requirements.
- Monthly reports will contain minimal information and only include ISAs where there have been subscription changes (e.g. new subscriptions, transfers, cancellations) during the month. Annual reporting will contain similar data to existing annual reports and will be for the entire ISA book.
- All reporting will need to be sent directly to HMRC via either an application programming interface (API) or a file upload via a portal. Software will need to be approved by HMRC before it can be connected to the API.
- Original discussions included the introduction of an investor ID field that would have needed to be populated for all ISA investors. However, HMRC have subsequently elected to continue to use National Insurance Numbers (NINo) rather than introduce a new data element.
- Oversubscriptions will be communicated by HMRC monthly, with ISA managers expected to implement any ISA repairs within two weeks.
- These proposed changes are likely to require significant operational and technological transformations for ISA managers. Managers will need to ensure they allow adequate time to implement these changes before the mandatory implementation date and have sufficient resources in place to manage the additional ongoing requirements that are expected to be set out in the updated guidance. The technical specifications for reporting are expected to be delivered in summer 2025, which has been brought forward from October 2025.
- Timing: the changes will come into force with a soft launch in April 2026 and mandatory implementation as from April 2027.
Resources (click to open)
- Update on HMRC’s digitalization initiative for ISA reporting (Deloitte tax@hand, April 2025)